Planning Commission
September 25, 2025
Proposal: WARM SPRINGS - LOPES ROAD APPEAL – 44960 Lopes Road - PLN2026-00023 - To consider a first -party (project proponent) Appeal of staff’s determination regarding the use of a
concession under State Density Bonus Law to lower an adopted minimum residential density below that required by the City’s General Plan, Warm Springs/South Fremont Community Plan, and corresponding Zoning Ordinance for a project proposed within a Transit -Oriented Development (TOD) Overlay District adjacent to the Warm Springs/South Fremont BART Station submitted under PLN2025-00253, and to consider a finding that no environmental review is required for the appeal action as, in isolation, it is not considered a "Project" under CEQA Guidelines Section 15378; and, on a separate and independent basis, without limitation, CEQA Guidelines Section 15270 (Projects Which Are Disapproved), as CEQA does not apply to projects which a public agency rejects or disapproves; and/or CEQA Guidelines Section 15061(b)(3) (Review for Exemption), in that there is no possibility that action on the Appeal would have a significant effect on the environment.
Recommendation: Deny the Appeal (uphold staff's decision).
Subject Site: 44960 Warm Springs Boulevard in the South Fremont Planning Area.
APN 519-1310-45
Area: 292,723-square-foot / ±6. 56-net-acre lot / ±6.72-gross-acre lot
People: Mark Kerslake, Newport Equities LLC., Appellant (Project Proponent)
Lopes Road LLC., Property Owner
Kevin Lee, Staff Planner | (510) 494-4521 | [email protected] General Plan: Innovation Center
Zoning: Warm Springs Innovation District - Planning Area 5 (WSI-5)
EXECUTIVE SUMMARY
The Planning Commission is being asked to consider a first -party Appeal of staff’s determination provided via a formal comment letter to deny the proposed use of a concession under State Density Bonus Law (“DBL”) to lower the adopted minimum residential density standard of 50 units per net -acre applicable to the 6. 56-net-acre subject Informational Item 2 - Planning Commission Staff Report
LOPES RD MULTIFAMILY DEVELOPMENT APPEAL
City Council Hearing
November 4, 2025
Planning Commission Report (ID # 5547) Meeting of September 25, 2025 WARM SPRINGS - LOPES ROAD APPEAL PLN2026-00023 Page 2
site. The requested density reduction would be necessary to facilitate the appellant’s proposed construction of approximately 127 attached townhome units where a minimum of 328 units would otherwise be required for the subject site. The Appeal is the subject of comments made by staff during the first review of formal entitlements for the proposed project (Informational Item “1”). The subject site is adjacent to the Warm Springs/South Fremont BART Station (“Station”) and is designated for development of high -density housing within the Transit -Oriented Development (“TOD”) Overlay District. The appellant asserts that staff’s denial of the proposed concession is in violation of DBL, which they contend allows for a significantly reduced project density of 19.4 dwelling units per net acre.
This Appeal does not address the project merits and only addresses threshold questions concerning: 1) whether the novel concession should be further evaluated or considered under DBL or rejected outright, and 2) whether CEQA review should proceed notwithstanding staff’s determination to not support the novel concession. Although it is atypical for an Appeal to be presented to the Planning Commission for a project that has not yet been deemed complete, Fremont Municipal Code (FMC) Section 18.300.020 provides that the decision of any City official, including Planning Division staff, may be appealed to the Planning Commission.
For the reasons contained in this report, staff recommends that the Planning Commission:
1) find that this Appeal (as distinct from the project itself) is exempt from environmental review pursuant to the California Environmental Quality Act (CEQA); and 2) deny the Appeal (upholding staff’s determination), which would reject the appellant’s request to direct staff to conduct CEQA review for the proposed project and disallow their request to lower the minimum density requirement through use of a concession under DBL because it is contrary to state law and should be denied pursuant to Government Code Section 65915(d)(1)(C), the fundamental purpose, goals, and policies for TOD outlined in the City’s General Plan and Warm Springs/South Fremont Community Plan and does not comply with the standards of the Zoning Ordinance, as further described in this report.
SITE CONTEXT, BACKGROUND, AND PREVIOUS ACTIONS
Site Context: The subject site is a relatively flat and undeveloped 6.7 2-gross-acre site with several habitable structures and a barn of unknown historic significance or date of construction. The subject site is immediately adjacent to the City’s Warm Springs Plaza and West Side Pedestrian & Bicycle Access Bridge of the Warm Springs/South Fremont BART Station.
Background/Previous Actions: On April 17, 2025, a “Preliminary Application” under Senate Bill 330 (Housing Crisis Act of 2019; SB 330) was received and deemed complete by staff.
The Preliminary Application included an attached townhome development consisting of 123 dwelling units with 30 optional junior accessory dwelling units (JADUs) for a then project density of approximately 18.3 dwelling units per acre. An SB 330 Preliminary Application allows a developer to provide a specific subset of information on a proposed housing development in advance of providing the full amount of information required for a full project application filing. Submittal of a complete Preliminary Application under SB 330 and payment of the required filing fee allows an applicant to "freeze" the applicable fees and development standards in effect at the time of Preliminary Application completeness and subject to future permit submittal timelines under state law.
Upon acknowledging receipt of the Preliminary Application submittal, staff informed the appellant that the project, as proposed, yields a project density considerably below the 50 Planning Commission Report (ID # 5547) Meeting of September 25, 2025 WARM SPRINGS - LOPES ROAD APPEAL PLN2026-00023 Page 3
units per net acre density minimum required for the subject site, and that the proposed project density, which would be achieved through use of a density bonus concession under DBL would be contrary to state law.
On June 4, 2025, the appellant, represented by counsel, sent an email to Planning Division staff containing two documents: a project statement with the request of a concession to lower the subject site’s required minimum density and an analysis of DBL that included a cost reduction study related to the proposed concession. These documents are included as part of the Appeal letter (Informational Item “2”). Planning Division staff inquired if the documents would supplement a future application; however, the City received no response.
On July 7, 2025, a formal entitlement application for the proposed project was received by the City under PLN2025 -00253 that included minor changes from the project proposed in the prior Preliminary Application submittal. The entitlement application project consists of 127 dwelling units with 33 optional JADUs across several three -story buildings for a slightly increased project density of approximately 19.4 units/net acre.
On August 6, 2025, the proposed project was deemed incomplete by staff within the statutory 30-day review period. A Notice of Incomplete was sent to the applicant through email while a formal comment letter was provided as a separate upload to the applicant’s project. The formal comment letter and Notice of Incomplete are enclosed with this staff report as Informational Item “1” and “3,” respectively. Although not required, the City provides preliminary feedback on an “incomplete project” as a courtesy to assist applicants on potential issues that may arise when a “complete project” is submitted.
On August 22, 2025, the Appeal was filed to contest two comments made by staff as part of the City’s August 6 formal comment letter. The appellant requested that the Appeal be heard at the next available calendared Planning Commission hearing.
Department of Housing and Community Development (HCD) – Technical Assistance Sought
After receiving the Appeal, staff promptly sought technical assistance regarding the matter from the Department of Housing and Community Development (HCD) through several email exchanges and one virtual meeting. At the time of writing this report, HCD has not provided any indication that staff’s decision to reject the proposed concession would be in violation of DBL or other state housing laws. Staff maintains the interpretation that DBL, as well as other State housing-related laws, are intended to maximize the production of housing. HCD generally agrees with and supports staff’s interpretation but are reticent to provide definitive formal guidance at this juncture, as the question ultimately is likely to be resolved by the State Legislature or through court interpretation. Based on recent offline conversations, HCD indicated that the agency has received at least five similar requests from other cities and has responded consistently with what was communicated with staff.
Due to these circumstances, staff recommends that the Planning Commission proceed with action on the appeal independent of any further guidance from HCD, as any response from HCD is unlikely to be definitive.
PROCEDURE FOR TONIGHT’S HEARING
The Planning Commission is being asked to consider the following:
1. A finding that action on the Appeal is exempt from the California Environmental Quality Act (CEQA), pursuant to, without limitation, each on a separate and independent basis, CEQA Guidelines Section 15378 (Project), as the action on the Planning Commission Report (ID # 5547) Meeting of September 25, 2025 WARM SPRINGS - LOPES ROAD APPEAL PLN2026-00023 Page 4
Appeal is not considered a “project”; CEQA Guidelines Section 15270 (Projects Which Are Disapproved), as CEQA does not apply to projects which a public agency rejects or disapproves; and/or CEQA Guidelines Section 15061(b)(3) (Review for Exemption), in that there is no possibility that action on the Appeal would have a significant effect on the environment; and
2. A finding that the proposed concession to reduce the City -adopted minimum density for the project site is inconsistent with and contrary to State law and should be denied pursuant to, without limitation, Government Code Section 65915(d)(1)(C), the fundamental purpose, goals, and policies for transit -oriented development outlined in the City’s General Plan and Warm Springs/South Fremont Community Plan, and standards of the Zoning Ordinance, for the reasons contained in this staff report; and
3. A denial of the first-party Appeal (upholding staff’s decision).
PROJECT DESCRIPTION
The appellant’s proposed project (filed under PLN2025 -00253) consists of a Discretionary Design Review Permit, Tentative Tract Map, and other entitlements to facilitate the construction of 127 townhome units within 21 three -story buildings across an approximately
6.56-net-acre lot located immediately west of the Station. While the project application has not been found complete, the project would appear to be eligible for consideration of one concession (or incentive) and an unlimited number of waivers under DBL because the appellant proposes to deed -restrict at least 10 percent of project units to low -income households and five percent to moderate-income households.
As part of the proposal, the appellant has requested a novel concession under DBL to reduce the required minimum density applicable to the project site from 50 units per net acre to approximately 19.4 units per net acre. City staff responded that the use of a concession to reduce a site’s minimum density requirement is contrary to DBL, the General Plan, the Warm Springs/South Fremont Community Plan, and the Zoning Ordinance and therefore would not be supported, which prompted the appellant’s Appeal filing.
APPEAL
On August 22, 2025, the appellant filed an Appeal after receiving staff’s formal comment letter dated August 6, 2025. In the Appeal letter (Informational Item “2”), the appellant’s counsel sets forth two issues outlined below.
1. Minimum Density Is A Development Standard. The appellant contends “that the minimum density standard is a ‘development standard,’ as defined and contemplated under DBL (Government Code Section 65915(k)), and that obtaining an incentive or concession to lower that density standard would result in identifiable and actual cost reductions, as required by DBL (Government Code Section 65915(d)(1).” Further, they note a minimum density standard is “inarguably a ‘development standard’ as broadly defined and contemplated under the DBL,” and that “DBL defines ‘incentives and concessions’ in relevant part as a ‘reduction in site development standards (Government Code Section 65915(k)…” The appellant believes that they have met the burden for requesting the proposed density reduction and have provided substantial evidence to show that request is consistent with DBL because it results in identifiable and actual cost reductions.
2. Environmental Review Not Performed Pursuant to CEQA For Project Denial Planning Commission Report (ID # 5547) Meeting of September 25, 2025 WARM SPRINGS - LOPES ROAD APPEAL PLN2026-00023 Page 5
Action. While the project application has not yet been deemed complete by staff and is not before the Planning Commission at this juncture, the appellant is requesting that the Planning Commission direct staff to perform environmental review for the proposed project, which would be required to be completed prior to any ultimate Planning Commission action to authorize the project to proceed.
APPEAL ANALYSIS
Staff recommends that the Planning Commission deny the appellant’s Appeal based on the following reasons:
Appeal Element: Minimum Density Is A Development Standard. The appellant argues that denial of the proposed concession to reduce the minimum required density is in direct violation of DBL.
Analysis:
a. The request is contrary to and inconsistent with DBL and other state and local housing goals, policies, and laws.
The proposed concession to lower the minimum density requirement through use of a concession under DBL is contrary to State law and should be denied pursuant to Government Code Section 65915(d)(1)(C). Staff views the use of a density bonus concession to lower an established minimum density standard as an infringement upon longstanding efforts at the state, regional, and local levels to add high -density housing where it is most appropriate and desired. Allowing a density reduction is contrary to State mandates that laws and regulations should be broadly construed insomuch as to maximize the development of housing within the state pursuant to Senate Bill 330 (Government Code Section 66300, approved as part of the Housing Crisis Act of 2019).
Legislation enabling density bonuses and other incentives are contained in California Government Code Section 65915. Government Code Section 65915(r) states that the chapter “shall be interpreted liberally in favor of producing the maximum number of total housing units .” In staff’s view, the appellant’s proposal would require the City to interpret DBL to allow production of fewer units than what is established by City - adopted minimum density standards, contrary to State law.
Furthermore, Government Code Section 65915(u) states:
(1) The Legislature finds and declares that the intent behind the Density Bonus Law is to allow public entities to reduce or even eliminate subsidies for a particular project by allowing a developer to include more total units in a project than would otherwise be allowed by the local zoning ordinance in exchange for affordable units. It further reaffirms that the intent is to cover at least some of the financing gap of affordable housing with regulatory incentives, rather than additional public subsidy.
(2) It is therefore the intent of the Legislature to make modifications to the Density Bonus Law by the act adding this subdivision to further incentivize the construction of very low, low -, and moderate-income housing units. It is further the intent of the Legislature in making these modifications to the Density Bonus Law to ensure that any additional benefits conferred upon a developer are balanced with the receipt of a public benefit in the form of adequate levels of affordable housing. T he Legislature further intends that these modifications will ensure that Planning Commission Report (ID # 5547) Meeting of September 25, 2025 WARM SPRINGS - LOPES ROAD APPEAL PLN2026-00023 Page 6
the Density Bonus Law creates incentives for the construction of more housing across all areas of the state.
Subsection (u)(1) intends to include more total units in a project than the standard allowance to cover the financing gap of affordable housing development instead of relying on public subsidies. Subsection (u)(2) also emphasizes that the intent of DBL ensures that additional benefits granted to developers through density bonuses and associated concessions in exchange for public benefit through adequate levels of affordable housing. Both subsections indicate that the law is intended to provide a greater, not lesser, number of units . Allowing a reduction in minimum density would fail to achieve this objective due to the resulting lost opportunities at the site for the development of higher density affordable housing for the foreseeable future. By extension, this reduction of density would consequently result in low -density development at sites where the opposite is desirable and planned for, hampering longstanding efforts to meet the housing production goals of the General Plan and State requirements.
HCD has developed numerous policies to address the State’s housing crisis and need for more housing opportunities at the local level, encapsulated through the Regional Housing Needs Assessment (RHNA). New legislation continues to further encourage or require, when used in exchange for certain incentives, high -density housing next to transit (e.g. pending SB 79, Wiener). Past HCD advisories have consistently emphasized that policies that allow for higher densities and higher production of housing are encouraged. State laws specifically prohibit local -level changes that would reduce minimum densities or create additional barriers to housing production.
In accordance with State law, the City has worked diligently to increase housing production within the City boundaries to meet its RHNA numbers. The Housing Accountability Act instructs local agencies to apply the highest available density standard allowed to ensure that the greatest amount of housing production is achieved, particularly at higher densities next to transit. Requiring the City to allow minimum density reductions through DBL concessions would result in lost opportunities to develop higher density housing in the most appropriate locations for the foreseeable future. This could significantly impair the City’s ability to reach its Housing Element goals, widen the gap of providing housing to all income levels, and could negatively impact the City’s ability to require sufficient adequate sites to be available at all times throughout the RHNA planning period, i.e., complying with “no net loss” under Senate Bill 166 (Government Code Section 65863).
In addition to addressing the housing shortage crisis, the City’s effort to maximize housing density around the Station coincides with collaborative local, regional, and state endeavors.
The subject site falls within the Priority Development Area (PDA), as recognized by the Metropolitan Transportation Commission (MTC), which is the coordinating agency for regional transportation efforts in the Bay Area’s nine counties. PDAs are key players of MTC’s Transit -Oriented Communities policy that specifically aims to increase the overall housing supply by increasing density for locations within one -half mile of BART and other transit stations. This goal is emphasized in Plan Bay Area 2050+, a long-range regional plan jointly developed and adopted by MTC and the Association of Bay Area Governments (ABAG) under Housing Strategy H3 to allow a greater mix of housing densities and types in Growth Geographies. Locally, the City’s BART stations would be identified by MTC as “Tier 2” stations, meaning growth around these stations should achieve a built density of at least 75 units per net acre or higher. There is no ceiling for density within the City’s Innovation District, and staff would be fully supportive of developers utilizing DBL to enable high - density residential development, not the opposite.
Planning Commission Report (ID # 5547) Meeting of September 25, 2025 WARM SPRINGS - LOPES ROAD APPEAL PLN2026-00023 Page 7
b. The request is inconsistent with the City’s General Plan, Warm Springs/South Fremont Community Plan, and Zoning Ordinance.
The proposed concession to reduce the minimum density requirement would be inconsistent with the fundamental purpose, goals, and policies for TOD outlined in the City’s General Plan and Warm Springs/South Fremont Community Plan and development standard of the Zoning Ordinance.
The site has a General Plan designation of Innovation Center and is zoned WSI -5. The goal of the designation is to create an urban mix of uses surrounding the Station that maximizes development intensities and densities. Accordingly, consistent with the City’s General Plan, the Community Plan sets the minimum residential density within one -quarter mile of the Station at a minimum of 50 units per net acre. This minimum density is also captured in the City’s zoning ordinance under Fremont Municipal Code (FMC) Table 18.49.070.
Under State law, local governments are required to plan for addressing community housing needs through the adoption of a Housing Element as part of their General Plan. The 2023 - 2031 Housing Element was adopted by City Council on January 10, 2023, and certified by HCD on March 22, 2023. The City’s Housing Element reflects the City Council’s vision for meeting housing needs, and explicitly and expressly directs growth towards areas where transit options are readily available. This directive is further encapsulated by the following General Plan and Housing Element policies:
General Plan Land Use Policy 2-1.7: Becoming a More Transit-Oriented City - Transit-oriented development (TOD) —or the placement of higher density uses around transit facilities —should be recognized as the key strategy for accommodating Fremont’s growth in the next 20-25 years.
Housing Element Policy 3.04: Intensify Residential Development within Urban Neighborhoods – Supports Goal 3 of the Housing Element to promote production of new affordable and market-rate housing.
The Innovation Center district measures approximately 879 acres surrounding the Station.
Leveraging significant investments made by BART, City, developers, and major employment sectors in the area, the goal for this district is to create an urban mix of uses surrounding the Station with the highest development intensities and densities. This is implemented by minimum floor area ratio (FAR) and density development standards contained in FMC
18.49.070, which is at 50 units per net acre for sites within one-quarter mile of the Station.
The Warm Springs Innovation (WSI) district provides development standards consistent with the City’s General Plan and the Warm Springs / South Fremont Community Plan. The importance of density for the Innovation Center is implemented by the Zoning Ordinance, as stated in FMC 18.49.070(d)(1):
“The number of dwellings per unit of land, the density, is controlled so that housing can match the availability of public services and the support of commercial areas.
The standards also allow the housing density to be matched with the carrying capacity of the land. In addition, the density standards are used as one type of control of overall building bulk. Finally, minimum density standards ensure that the service capacity is not wasted and that the city’s housing goals are met.” Per FMC Table 18.49.070, as previously mentioned, new residential development must meet the minimum 50 units per net acre standard within one -quarter mile of the Station. The project set forth by the appellant proposes a significant density shortfall at approximately Planning Commission Report (ID # 5547) Meeting of September 25, 2025 WARM SPRINGS - LOPES ROAD APPEAL PLN2026-00023 Page 8
19.4 units/net acre, inconsistent with the General Plan, Warm Spring/South Fremont Community Plan, and Zoning Ordinance. Per State law, failure to follow a certified Housing Element risks loss of permitting authority, financial penalties, court receivership, and other consequences through enforcement by HCD. Numerous State legislation has authorized HCD to review any action or failure to act by a local government that HCD finds inconsistent with an adopted Housing Element. The City routinely processes DBL applications to maximize affordable housing and density.
Additionally, to require the City to approve housing below established minimum densities could put the City at a disadvantage and risk of not receiving grant funding if the implementation of adopted TOD plans is not realized, as development policies under MTC require intensified development near transit. DBL was adopted to allow projects to exceed the maximum allowable densities expressed in the General Plan, not used as a vehicle to reduce density to support considerably lower density housing next to transit , which would be consistent with MTC’s Transit-Oriented Communities (TOC) policies.
Appeal Element: Environmental Review Not Performed Pursuant to CEQA For Project Denial Action. The appellant is requesting that the Planning Commission direct staff to perform environmental review for the proposed project that may subsequently be considered by the Planning Commission.
Analysis:
The appellant is requesting that the Planning Commission direct staff to complete environmental review for their proposed project, citing that the City would be in violation of the Permit Streamlining Act’s approval time limits. While staff has relayed that the City’s standing practice, as lead agency, is to not perform environmental review for projects for which it recommends denial, staff recommends that the Planning Commission deny this request for environmental review as it is premature at this stage to determine what environmental review will be required for the proposed project.
In addition, the project’s “incomplete” status as previously established justifies no environmental review to be conducted at this time. In accordance with the Permit Streamlining Act (Government Code Section 65943), the City has 30 days after the application is deemed complete, when the lead agency must determine whether the project requires an environmental impact report (EIR), negative declaration, or can be exempt (Public Resources Code Section 21080.1, CEQA Guidelines Section 15060 -15063). If a negative declaration must be prepared, the lead agency must complete and adopt it within 180 days of the application being deemed complete (Government Code Section 65950, Public Resources Code Section 21151.5). If an EIR is required, the lead agency must certify the EIR within one year from when the application is deemed complete, unless the appellant agrees to an extension (Government Code Section 65950(a)(1)).
Finally, CEQA Guidelines Section 15270(a) states:
“CEQA does not apply to projects which a public agency rejects or disapproves.”
Pursuant to CEQA Guidelines Section 15270, the lead agency is not required under the law to conduct environmental review of a project that is recommended for denial. CEQA applies only to projects that an agency proposes to carry out, support or approve, therefore, projects that are rejected or disapproved are exempt from CEQA. Case law has held that CEQA does not require a lead agency to commit resources to environmental review of a proposed private project that is slated for rejection. (see e.g., Las Lomas Land Co. v. City of Planning Commission Report (ID # 5547) Meeting of September 25, 2025 WARM SPRINGS - LOPES ROAD APPEAL PLN2026-00023 Page 9
Los Angeles, 177 Cal. App. 4th 837 (2009).
In closing, staff urges the Planning Commission to deny the Appeal . Granting the Appeal would result in a fundamental inconsistency with the General Plan’s mission statement and would conflict with its key goals and policies for creating higher density housing and jobs near transit. The City’s effort to maximize housing density around the Station aligns with local, regional, and state development policies and goals for urban development next to transit should be upheld.
ENVIRONMENTAL REVIEW
Environmental review is not applicable as action on the Appeal is not considered a “project” per the definition contained in CEQA Guidelines Section 15378 (Project). In addition, each on a separate and independent basis without limitation, the action on the Appeal is exempt pursuant to CEQA Guidelines Section 15270 (Projects Which Are Disapproved), as CEQA does not apply to projects which a public agency rejects or disapproves and/or CEQA Guidelines Section 15061(b)(3) (Review for Exemption), in that there is no possibility that action on the Appeal with have a significant effect on the environment.
PUBLIC NOTICE AND COMMENT
Public hearing notification is applicable. A total of 808 notices were mailed to owners and occupants of property within 300 feet of the site. The notices to owners and occupants were mailed on September 12, 2025. A Public Hearing Notice was published by The Tri-City Voice on September 9, 2025.
The City received 13 emails from members of the public at the time of report publishing in response to public noticing for the Appeal . These emails are compiled and provided under Informational Item “4.”
RECOMMENDATION
1. Hold public hearing.
Based on the evidence in the record and presented at the public hearing:
2. Find that action on the Appeal is exempt from the California Environmental Quality Act (CEQA), pursuant to, without limitation, each on a separate and independent basis, CEQA Guidelines Section 15378 (Project), as the action on the Appeal is not considered a “project”; CEQA Guidelines Section 15270 (Projects Which Are Disapproved), as CEQA does not apply to projects which a public agency rejects or disapproves; and/or CEQA Guidelines Section 15061(b)(3) (Review for Exemption), in that there is no possibility that action on the Appeal would have a significant effect on the environment; and
3. Find that the proposed concession to reduce the required minimum density is inconsistent with and contrary to State law and should be denied pursuant to Government Code Section 65915(d)(1)(C), the fundamental purpose, goals, and policies for the transit -oriented development outlined in the City’s General Plan and Warm Springs/South Fremont Community Plan, and standards of the Zoning Ordinance, for the reasons contained in this staff report; and
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4. Deny the first-party Appeal (upholding Staff’s decision).
ENCLOSURES
• Informational 1 - Development Review Comment Letter
• Informational 2 - Appeal Letter
• Informational 3 - Notice of Incomplete
• Informational 4 - Public Correspondence